The Supreme Court affirmed the dismissal of two Philippine Postal Corporation employees for falsifying their educational attainment in their Personal Data Sheets (PDS). This ruling underscores the serious consequences for public servants who misrepresent their qualifications to gain promotions, emphasizing the importance of honesty and integrity in public service.

Deceptive Degrees: Can False Claims Justify Dismissal?

Consolacion A. Lumancas and Yolando O. Uriarte, employees of the Philippine Postal Corporation, faced charges filed by a co-worker, Virginia B. Intas, alleging they made false entries about their education in their PDS forms. These misrepresentations, the complaint stated, led to their promotions, disadvantaging other employees with longer tenures. The Office of the Ombudsman investigated and discovered inconsistencies in Lumancas’ educational records. For instance, her PDS forms from different years provided conflicting information about her degrees and attendance at Centro Escolar University and International Harvardian University (IHU). Similarly, Uriarte claimed to have a Bachelor of Science in Commerce from IHU, but the Bureau of Higher Education denied issuing the special order validating his degree. Both Lumancas and Uriarte insisted on the authenticity of their credentials and denied any intent to falsify information.

The Ombudsman’s investigation revealed significant discrepancies in both petitioners’ academic records. Lumancas’ educational attainment was listed as Fourth Year Pharmacy in her original appointment, yet her PDS forms claimed different degrees and attendance periods at various institutions. The IHU could not provide the original of her Special Order, and her name was absent from the IHU enrollment lists filed with the Higher Education Division. Uriarte’s case was similar, with the Bureau of Higher Education denying the issuance of his Special Order. These discrepancies led the Ombudsman to conclude that both Lumancas and Uriarte had misrepresented their educational qualifications. The petitioners argued that their mistakes were unintentional and that their promotions were based on overall qualifications and performance.

The Ombudsman, however, found them guilty of falsification, dishonesty, and grave misconduct, leading to their dismissal. Section 27 of RA 6770, The Ombudsman Act of 1989, states that “(f)indings of fact by the Office of the Ombudsman when supported by substantial evidence are conclusive.” The Ombudsman’s office determined that the evidence supported the conclusion that neither Lumancas nor Uriarte had obtained the college degrees they claimed. The certification from Severina O. Villarin, initially relied upon by the petitioners, was later retracted by Villarin herself, who confirmed that the Special Orders were spurious. Despite the burning of records at the DECS Regional Office XI in 1991, records at DECS-CHED did not show their enrollment at IHU during the relevant years.

Further scrutiny of DECS records revealed that the petitioners’ names were not on the list of students enrolled at IHU during their alleged period of study. Laura Geronilla, Assistant Registrar of IHU, claimed that omissions were possible when preparing Form 19 by hand. The Court found this explanation unconvincing, noting the repeated omissions across multiple semesters and school years, leading to the conclusion that the petitioners were never officially enrolled. The court referenced Diaz v. People, highlighting that the accused failed to provide corroborating evidence of their enrollment despite opportunities to do so.

The Supreme Court emphasized that falsifying a PDS is grounds for disciplinary action. Lumancas had inconsistent entries across her PDS forms from 1989, 1991, and 1993. Similarly, Uriarte made conflicting entries in his PDS forms from February 1987 and March 1990. Public servants, especially those seeking promotion, are expected to uphold high ethical standards. Chapter 7, Sec. 46, Book V, of EO 292 (Administrative Code of 1987) lists dishonesty and falsification of official documents as grounds for disciplinary action. The Court clarified that this was an administrative case, not a criminal one, and any of the cited charges could justify disciplinary action.

The elements of falsification through untruthful statements were present in this case. These elements include: making statements in a document, a legal obligation to disclose the truth, absolute falsity of the narrated facts, and wrongful intent to injure a third person. The court in People v. Po Giok To, held that in falsification of public documents, the intent to injure is not necessary, as the violation of public faith is the primary issue. While the petitioners argued their PDS forms were not sworn before an officer, removing the case from perjury, the Court disagreed that there was no obligation to disclose the truth. The Court referred to Inting v. Tanodbayan, which established that completing a PDS is connected with government employment, making any untruthful statement a matter of concern. Thus, the Supreme Court affirmed the Ombudsman’s decision, dismissing the petition and upholding the dismissal of Lumancas and Uriarte from the service.

FAQs

What was the key issue in this case?	The central issue was whether the falsification of educational attainment in Personal Data Sheets (PDS) by public employees warrants their dismissal from service.
What is a Personal Data Sheet (PDS)?	A Personal Data Sheet (PDS) is an official document required by the Civil Service Commission for government employees. It contains information about an employee’s personal background, educational attainment, and work experience, and is used for various administrative purposes, including promotion.
What were the discrepancies found in Lumancas’ PDS?	Lumancas made inconsistent entries in her PDS forms regarding her educational attainment, claiming different degrees and attendance periods at Centro Escolar University and International Harvardian University in different years.
What evidence was used against Uriarte?	The Bureau of Higher Education denied issuing the Special Order validating Uriarte’s Bachelor of Science in Commerce degree, leading the Ombudsman to conclude he had misrepresented his educational qualifications.
What does RA 6770 say about the Ombudsman’s findings?	Section 27 of RA 6770, The Ombudsman Act of 1989, states that findings of fact by the Office of the Ombudsman, when supported by substantial evidence, are conclusive.
What is the legal basis for disciplinary action in this case?	Chapter 7, Sec. 46, Book V, of EO 292 (Administrative Code of 1987) lists dishonesty and falsification of official documents as grounds for disciplinary action against government employees.
What was the Court’s ruling in Inting v. Tanodbayan?	The Court in Inting v. Tanodbayan established that completing a PDS is connected with government employment, making any untruthful statement a matter of concern and subject to disciplinary actions.
What is the significance of People v. Po Giok To in this case?	People v. Po Giok To clarified that in falsification of public documents, the intent to injure is not necessary, as the violation of public faith is the primary issue.
What was the final decision of the Supreme Court?	The Supreme Court affirmed the Ombudsman’s decision, dismissing the petition and upholding the dismissal of Lumancas and Uriarte from their positions in the Philippine Postal Corporation.

This case serves as a critical reminder of the importance of honesty and integrity in public service. Misrepresenting qualifications not only undermines the credibility of public institutions but also disadvantages honest and deserving employees.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Lumancas v. Intas, G.R. No. 133472, December 5, 2000